ML12198A173

Attachment to Enclosuexecutive Summary

ML12198A173
Person / Time
Site:	Palisades
Issue date:	08/15/2012
From:	Macfarlane A NRC/Chairman
To:	Markey E US Congress, US HR (House of Representatives)
Rihm, Roger 415-1717
Shared Package
ML12191A401	List: ML12178A446 ML12191A402 ML12198A171 ML12198A173
References
G20120453, LTR-12-0298, SECY-2012-0330, CORR-12-0073
Download: ML12198A173 (3)

Text

EXECUTIVE

SUMMARY

This report describes the results of an independent assessment of the existing Safety Culture andSafety Conscious Work Environment at the Palisades Nuclear Power Plant. The populationaddressed in the assessment included all Entergy Employees at the Palisades Nuclear PowerPlant and long term contractors based at Palisades. The assessment was conducted duringJanuary and February, 2012. The primary objective of the assessment was to provideinformation regarding the status of the safety culture components at Palisades as recentlydescribed by the U.S. Nuclear Regulatory Commission (NRC). The assessment was conductedusing the same methodology that aligns with the current U.S. NRC procedures for independentsafety culture assessment. Positive observations and areas in need of attention with respect to thecomponents are presented. Conclusions regarding the results of the information collected on thesafety culture components are also presented to facilitate the identification of improvementstrategies.The safety culture components important for the existence of a healthy safety culture within anuclear facility have been identified (INSAG-15, 2002; INPO Principles for a Strong NuclearSafety Culture, 2004; U.S. NRC Inspection Manual 0305, 2006). The U.S. NRC has definedthese components to include:Human Performance 1.Decision-Making 2.Resources 3.Work Control 4.Work PracticesProblem Identification and Resolution 1.Corrective Action Program 2.Operating Experience 3.Self and Independent AssessmentsSafety Conscious Work Environment 1.Environment for Raising Concerns 2.Preventing, Detecting, Mitigating Perceptions of RetaliationOther Safety Culture Components 1.Accountability 2.Continuous Learning Environment 3.Organizational Change Management 4.Safety PoliciesPerformance attributes are associated with each of the safety culture components. Particularbehaviors and attitudes have been identified to evaluate the extent to which the organization hasattained these attributes.Most of the methodology used in this assessment was based upon work originally developedwith the support of the U.S. NRC to assess the influence of organization and management onsafety performance. The methodology entails collecting a variety of information that is largelybased upon the perceptions of the individuals in an organization, as well as conducting structured observations of individuals performing work activities. Perceptions are often reality when itcomes to influencing behavior and understanding basic assumptions. Therefore, the datacollected regarding individuals' perceptions are critical to this type of assessment.The results of this assessment have been presented in the U.S. NRC framework for evaluatingthe components important to safety culture. In the context of that framework, the AssessmentTeam identified that there are positive observations and areas in need of attention within each ofthe 4 primary areas of safety culture and specific examples are presented for each component ineach of the areas. In addition, areas for improvement are identified in the Conclusion Section ofthe report and are based upon the information collected for each component of the safety culture areas.In general:Human PerformanceThe Team noted that important decision making processes are governed by corporate proceduresand appear to be consistent with industry practices. However, several events have occurred inrecent Palisades history in which deviation from those processes contributed to the occurrence orseverity of an event. Standards and expectations with respect to work practices and work controlneed to be more clearly communicated and reinforced. Formality and consistency in theimplementation of human error prevention techniques needs to be implemented.The Team believes that there is a lack of confidence and trust by the majority of employees (bothstaff and management) at the Plant in all levels of management to be open, to make the rightdecisions, and to really mean what they say. This is indicated by perceptions around thedecisions that have been made, the mixed messages and lack of adherence to expectations bymanagement and supervision, and in the repeated emphasis of production over safety exhibitedthrough decisions around resources.Problem Identification and ResolutionIndividuals across the organization indicated their willingness to raise and escalate issues. TheCR process is perceived by Plant personnel as easily accessible and well used by employees atall levels. However, the value of the process to create a learning organization is not being fullyrealized. Senior leadership provides weak oversight of the process and management engagementwith the process is limited to high level issues, with no regular forum to assess the health of theprogram. Operating experience needs to be better integrated into a learning process and astronger independent oversight organization that management will listen to is needed to helpidentify areas for performance improvement.There is a lack in the belief that Palisades Management really wants problems or concernsreported or that the issues will be addressed. The way that CAP is currently being implementedis not perceived as a value added process for the Plant. The relationship of the CAP toperformance improvement and the role it plays in the development of a learning organization isnot understood or recognized by most individuals.

Safety Conscious Work EnvironmentThe results of this assessment do indicate that the Palisades Plant has issues with respect to asafety conscious work environment. While the majority of employees believe that managementsays that retaliation would not be tolerated, there is also a widespread perception of fear andpunishment across the Plant. The Team believes that an Area for Improvement must beidentified for the perception that the majority of employees believe that they cannot challengemanagement decisions, that helpful criticism is not encouraged, and that they cannot approachmanagement with concerns.The absence of a dominant constructive cultural style at the Plant indicates that management hasnot been successful in communicating and reinforcing the values and attitudes that areimportant for enhancing safety culture. Further evaluation and understanding of why there issuch pervasiveness and consistency across the Plant around these issues is critical in movingforward for effective progress to be made for ensuring a healthy safety culture.Other Safety Culture ComponentsExamples of a lack of accountability at all levels at the Plant were evident. Many individuals inmanagement and supervision do not consistently exhibit desired behaviors and are notchallenged by their managers or peers. Inconsistent implementation of standards andexpectations in work activities are common and may be facilitated by ineffective communicationaround the change management process. Significant management oversight and attention isneeded to communicate the standards and expectations and implement the appropriate andconsistent performance management to hold individuals accountable.The Team believes that a contributing factor to the accountability issue is that there are too manyexpectations and standards identified without a clear prioritization of which ones are mostimportant. Additionally, the negative perceptions around the communication process at the Plantmust be improved in order for any messages to be heard, understood, and implemented toachieve the desired performance.